CODE's Privacy Policy

1. CODE's Commitment to the Protection of Personal Information

At CODE, we attach a very high value to the trust that our donors place in the organization they have chosen to support. Accordingly, so as not to abuse that trust, we will use our best efforts to limit the collection and use of personal information about our donors and to protect the confidentiality of that information. Generally speaking, "personal information" for the purposes of this Policy is information about an identifiable individual.

2. The Personal Information that CODE Collects and Maintains about Donors

The information we collect about a donor or prospective donor that may, alone or in combination, constitute personal information include name, home contact information, credit card or bank account information (for the purpose of our collecting a donation), countries, programs or projects an individual wishes to support, language preference, demographic information (such as age and gender) and future communication preferences. The personal information that we maintain about a donor or prospective donor may include any of this information that we have collected about the donor or prospective donor and the amounts and manner in which he or she has contributed or promised to contribute to CODE.

3. The Purposes for which CODE Collects Personal Information about Donors and the Sources of that Information

We collect personal information about donors and prospective donors for the following purposes:

• Conducting and facilitating fundraising,
• Managing our relationship with donors, and
• Meeting any legal or regulatory requirements relating to the activities of CODE.

Any such personal information, collected for these purposes, will be collected from the individual to whom it relates but may be collected from a third party with the individual's knowledge and consent or from a publicly available source of information, such as a telephone directory.

In collecting the personal information on a donor list provided to us by way of exchange from another charitable organization we will ask for and obtain a representation from that organization to the effect that the individuals on its list have given their consent expressly or implicitly to the sharing of their personal information in this way. Any information – in particular, the name and address of any donor – on a list provided to CODE by another organization, through an exchange of donor lists, will be held by an independent mailing house. CODE will only be made aware of such personal information if and when the individual to whom it relates contacts CODE, in response to a communication made through the mailing house and provides the information to CODE

4. The Uses of Personal Information about Donors by CODE

We will not use personal information that has been collected for one or more of the purposes described above for any other purpose or purposes without the knowledge or consent of the individual to whom the information relates, except as specifically permitted under any applicable personal information protection legislation.

5. The Disclosure of Personal Information about Donors by CODE

We will not disclose any personal information about a donor or prospective donor to anyone outside CODE or any of its affiliated entities without the knowledge or consent of that donor or prospective donor except as follows;

• To an auditor in connection with an audit of CODE conducted by its auditor or by an auditor retained by CODE's principal funding agency, the Canadian International Development Agency,
• To an organization or individual providing services to CODE where the personal information is reasonably required in the performance of those services, provided that contractual or other arrangements are made to ensure that any such organization or individual acts in a manner consistent with this Policy and uses such personal information solely for the purpose of providing services to CODE or on its behalf in a manner consistent with our instructions,
• To a lawyer who is representing CODE in a matter to which the personal information relates,
• To comply with a subpoena, warrant or requirement under an order or rule of court,
• To a government institution that has made a request for the information, identifying its authority to do so, in connection with the administration of any law of Canada or a province, or
• In any other circumstance where disclosure is specifically permitted under any applicable personal information protection legislation.

While we never sell or rent out our donor lists, we may provide a donor list to another reputable charitable organization pursuant to an arrangement for the exchange of donor lists with that other organization (as described in section 3 above). In that event, the only personal information about any of our donors that we will disclose on our donor list will be the names and addresses of those donors. We will not disclose any other personal information about a donor, such as the amount or level of contribution made or promised to CODE by the donor. No donor's name or address, comprising personal information, will be included on a list of donors provided by CODE to another charitable organization without the knowledge and consent of that donor. That knowledge and consent may be implied if the donor has not:

• Marked the appropriate box on any donation form or other document (in electronic or hard copy) provided to the donor, indicating that the donor objects to the sharing of his or her personal information with any other organization for fundraising purposes, and
• Returned the form or other document, so marked, to CODE.

If a donor who has given express or implied consent to the sharing of his or her name and address with other charitable organizations for fundraising purposes wishes to have that information excluded, in future, from any donor list that CODE might exchange with another charitable organization, the donor may simply notify us in writing to that effect at CODE's address set out at the end of this Policy, to the attention of the Executive Director.

We will act on any such notification within seven days of its receipt. If we have already exchanged a list that includes the donor's name and address with another charitable organization at the relevant time, we may be unable to prevent the use of that information by the other organization.

6. The Retention and Destruction of Personal Information about Donors

We keep personal information about donors and prospective donors for as long as required by law or to fulfill the purposes for which it was collected. We take reasonable steps to destroy, delete or erase personal information that is no longer required.

7. The Security of Personal Information about Donors

We endeavour to maintain adequate physical, procedural and technical security with respect to our offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure or modification of personal information about donors or prospective donors. Our employees are made aware of the importance of maintaining the confidentiality of such personal information.

8. Access by Donors to their Personal Information and the Right to Correct that Information

A donor or prospective donor may make a request to us in writing for access to any of his or her personal information held by CODE. We will respond with due diligence and within a reasonable time by providing access to that information except in circumstances where we are entitled or required to refuse access under any applicable personal information protection legislation. A donor or prospective donor who believes that any of his or her personal information held by CODE is inaccurate or incomplete may make a request to us in writing to amend that information and we will make the appropriate amendment unless we are of the reasonable opinion that the information is not inaccurate or incomplete, in which case we will make a notation, in CODE's records, of the requested amendment.

9. General Responsibility at CODE for Compliance with this Policy

The Executive Director of CODE shall have overall responsibility for our compliance with this Policy and with any applicable personal information protection legislation as it applies to personal information about donors and prospective donors. Any complaints about our handling of such personal information shall be made in writing and directed to the Executive Director of CODE at the address set out below.

10. Effective Date of this Policy and Amendments to the Policy

This Policy is effective as of April 1, 2005. We may amend this Policy from time to time and any such amendment shall apply in respect of the collection or generation of personal information about donors or prospective donors from the effective date of the amendment and in respect of personal information about donors or prospective donors then held by CODE. The latest version of this Policy will always be posted on our Web site, the address of which is set out below.

11. Contact Information

Questions, concerns or complaints regarding CODE’s privacy policy or practices should be directed to our Executive Director at (613) 232-3569 or toll-free at 1-800-661-2633.